Irving Bank-Columbia Trust Co. v. Commissioner
United States Board of Tax Appeals
1. Evidence submitted as to the value of certain shares of stock included in decedent's gross estate held insufficient to overcome presumption existing in favor of the correctness of respondent's determination. 2. Held that the transfer of certain shares of stock of the same corporations was not made in contemplation of death or intended to take effect in possession or enjoyment at or after death. 3. There may be deducted from petitioner's gross estate in determining the net…
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1. Evidence submitted as to the value of certain shares of stock included in decedent's gross estate held insufficient to overcome presumption existing in favor of the correctness of respondent's determination. 2. Held that the transfer of certain shares of stock of the same corporations was not made in contemplation of death or intended to take effect in possession or enjoyment at or after death. 3. There may be deducted from petitioner's gross estate in determining the net estate subject to taxation a reasonable amount for executors' commissions and attorneys' fees, even though the amount…
1Opinion of the Court
*902OPINION.
ARUndedl:
In their estate-tax return the executors valued the stock held by the testator in the Company and Corporation at $500 and $62.83 per share, respectively, which values the respondent increased to $735 and $90. The values fixed by the respondent are based entirely upon the book value of the assets behind the stocks, less an amount regarded as sufficient to compensate for the fact that the decedent died a short time after a period of high earnings. The petitioners are contending that the allowances made are insufficient, considering the nature of the businesses, the decline in…
2Cases cited2 opinions
- In Re the Estate of BrandrethNew York Court of Appeals · 1902
- In Re the Appraisal, Under the Transfer Tax Act, of the Estate of CornellNew York Court of Appeals · 1902
3Cited by11 opinions
- Stewart v. CommissionerUnited States Board of Tax Appeals · 1934
- Estate of Prell v. CommissionerUnited States Tax Court · 1967
- Estate of Bullock v. CommissionerUnited States Tax Court · 1960
- Estate of Henning v. CommissionerUnited States Tax Court · 1977
- Degener v. CommissionerUnited States Board of Tax Appeals · 1932
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